Project MS 17/03 – Post-implementation review (PIR) – Part 145 approved maintenance organisations
To carry out a post implementation review of CASR Part 145.
Issues identified include:
- over complex and restrictive legislation to permit specialist maintenance organisations to provide an appropriate level of certification for the maintenance services they provide under their own scope of approval which is not consistent with EASA
- lack of clarity for the requirements and differences between specialist maintenance performed within the limitations of the D rating scope of approval versus specialist maintenance which is required to be performed under the respective A, B and C ratings
- clearer guidance required on the intent of the specialist maintenance class and D rating as support for the maintenance of aircraft and aeronautical products under the other Part 145 class and ratings
- the provision for the standalone specialist maintenance class D rating approved maintenance organisation (AMO) to employ holders of a Part 66 aircraft engineer licence is not practical
- the complexity and difficulties of establishing what maintenance can be categorised as specialist maintenance under the D3 rating scope of approval
- inconsistent application of the scope of approval for D3 rating provisions, including the specialist maintenance listed under 145.A.30(f) of the Part 145 MOS.
- lack of clarity for the overall applicability, associated functionality and scope for each of the Part 145 Manual of Standards (MOS) Class, Rating and limitations provisions
- uncertainty of the expectations and applicability of the certification requirements for aircraft and aeronautical product maintenance which vary within the Part 145 scope of approval ratings and limitations provisions
- ambiguities with the interpretation and intent of the requirements for competencies to carry out or supervise maintenance
- potential outcomes from the post implementation review of Part 66 including aircraft maintenance engineer licences and ratings may impact the Part 145 legislation
- the applicability for the adoption, implementation and management requirements of a maintenance organisation’s capability list
- confusion with terminology and definitions for the privileges and requirements for contracting and subcontracting maintenance services to approved and non-approved organisations
- restrictive legislation provisions do not permit a Part 145 approved maintenance organisation (AMO) to provide occasional scheduled line maintenance other than at locations listed within the AMO exposition which is inconsistent with the EASA provisions
- inadequate legislation for the provisions of performing aeronautical product maintenance whilst the product is fitted to the aircraft
- consideration of other CASA regulations which permit maintenance by a Part 145 AMO for aircraft operating under the CAR 1988 requirements
- future development to consolidate safety management system legislation will require subsequent changes to the Part 145 MOS.
- the CASR Part 42 maintenance certification requirements for maintenance tasks completed on aircraft is a provision which is specified differently from EASA.
- consideration of proposed policy or legislation amendments for the potential impact to current national aviation authority bilateral agreements, technical arrangements and associated participating organisations.
- ensure that the legislation effectively addresses the relevant safety risks
- maintain compliance with ICAO standards
- improve international harmonisation
- reduce the complexity of the legislation
- improve the harmonisation between related CASR legislation
- improve, where applicable, scalability of the requirements
- fix any anomalies in the legislation and address unintended consequences
- remove ambiguities and generally streamline the legislation
- resolve policy and functionality requirements for specialist maintenance
- identify and provide interim measures to alleviate some of the complexities and burdensome requirements until changes are implemented.
This project was approved by the Manager, Airworthiness Standards Branch 2 August 2017.
- Part 42 of CASR
- Part 66 of CASR
- Part 145 of CASR
- Part 145 MOS
Project Leader: Robert Park
Project Sponsor/s: Manager, Airworthiness Standards Branch
|Consultation updates in 2017|
|PIR 1711MS – Part 145 continuing airworthiness - approved maintenance organisations||Comments close 16 Feb 2018.||19 December 2017|
|Project MS 17/03 – Post-implementation review (PIR) – Part 145 approved maintenance organisation||Project approved.||15 December 2017|